Preliminary comments on the revision of Annex II of the RoHS Directive - Joint submission from CEFIC, Eurometaux, Orgalime & PlasticsEurope

We acknowledge that the updated Methodology for Identification and Assessment of Substances for Inclusion in the List of Restricted Substances under the RoHS2 Directive ('RoHS Methodology') as presented during the 2nd stakeholder meeting and described in the Draft Manual released by the Austrian UBA on 7 May has integrated some of the issues raised during the second consultation:

• References to the REACH Regulation where the assessment of substances is concerned
• Reference to chapter R.18 of the ECHA guidance on exposure scenario building for the waste life phase
• Clearer decision trees and improved criteria for prioritisation

However, we believe that the methodology should be further improved in order to ensure that the implementation of the RoHS2 directive achieves maximum coherence and efficiency in dealing with its main remit, which is the restriction of hazardous substances used in electrical and electronic equipment ('EEE'). More emphasis is therefore needed on the assessment, including the waste phase, rather than on the production volume as is the case in the Draft Manual.